Transfer Pricing in Ghana: What Multinationals Need to Know
What is Transfer Pricing?
Transfer pricing refers to the prices charged between related parties — such as a parent company and its Ghanaian subsidiary — for goods, services, loans, intellectual property, and other transactions. Ghana's rules require that these transactions be conducted at arm's length.
Legal Framework
Transfer pricing in Ghana is governed by the Income Tax Act, 2015 (Act 896) and the Transfer Pricing Regulations, 2020 (L.I. 2412). Ghana's rules are broadly aligned with the OECD Transfer Pricing Guidelines.
Accepted Methods
- Comparable Uncontrolled Price (CUP)
- Resale Price Method (RPM)
- Cost Plus Method (CPM)
- Transactional Net Margin Method (TNMM)
- Profit Split Method (PSM)
Documentation Requirements
Companies with controlled transactions exceeding GHS 100,000 in a year of assessment are required to prepare and maintain contemporaneous transfer pricing documentation, including a functional analysis, description of transactions, and a benchmarking study.
Penalties for Non-Compliance
- Income adjustments to reflect arm's length pricing
- Penalty of 25–50% of the underpaid tax
- Interest on unpaid amounts
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Published by
Ghana Tax Insights
Disclaimer
For general information only — not professional tax advice. Consult a qualified advisor for your specific situation.
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